Financial Hardship Policy · Financial Hardship Policy Private and Confidential Version 0.7 Date First Published 1 July 2010 ... 5.2 Breaking a Fixed Term Interest Period

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Financial Hardship Policy

Private and Confidential

Version 0.7 Date First Published 1 July 2010 Date Last Updated 31 May 2013

WBC.107.005.0316

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Contents

Revision History ................................................................................................................................... 3

Introduction .......................................................................................................................................... 4

1. The Assist Group .......................................................................................................................... 4

1.1 What is the Assist Group? ..................................................................................................... 4

1.2 Who does the Assist Group help? ......................................................................................... 4

2. Types of Financial Hardship Assistance Offered by the Assist Group ........................................... 5

2.1 Account Restructure .............................................................................................................. 5

2.2 Escalation to Long Term or Permanent Collection Procedures ............................................ 5

3. Processing a Request for Hardship Assistance ............................................................................ 6

4. Eligibility and Assessment for Financial Hardship ..................................................................... 7

4.1 Assistance Eligibility.................................................................................................................. 7

4.1.1 General Eligibility Criteria ..................................................................................................... 7

4.1.2 Assessment .............................................................................................................................. 8

4.1.3 Customers requiring Administrator/Executor approvals ........................................................ 8

5. Secured Loan exceptions .............................................................................................................. 8

5.1 Mortgage Insured Loans............................................................................................................. 8

5.2 Breaking a Fixed Term Interest Period ...................................................................................... 9

5.3 Building Insurance ..................................................................................................................... 9

5.4 Maximum Lending to Value Ratio (LVR) ................................................................................. 9

5.5 Guaranteed Loans ....................................................................................................................... 9

6. Enforcement Action ..................................................................................................................... 9

7. Appendix A - Legislation .......................................................................................................... 10

7.1 NCC Requirements .................................................................................................................. 10

7.2 The Code of Banking Practice ................................................................................................. 12

8. Appendix B - Credit Authority Limits (CALs) .......................................................................... 13

9. Appendix C – Financial Capacity Calculator (FCC) ................................................................. 15

10. Appendix D - Mortgage Solutions Table ................................................................................ 17

11. Appendix E - Credit Card Account Assistance Matrix ........................................................... 20

12. Appendix F - Personal Loan Account Assistance Matrix ....................................................... 21

13. Appendix G - Transaction Account Restructure Table .......................................................... 22

14. Appendix H - Equipment Finance Account Restructure Table .............................................. 23

15. Appendix I - Glossary ............................................................................................................. 24

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Revision History

Version Issue Date Description of Version / Changes Author

V0.1 12 February 2010 Initial draft circulated for comment Amanda Ellis

V0.2 24 March 2010 Incorporation of feedback from initial draft, additional details around LMI requirements for Mortgages, Business Loan and Equipment Finance account restructure tables, updated CAL matrix

Amanda Ellis

V0.3 31 March 2010 Incorporation of feedback from Review and Sign-off process

Amanda Ellis`

v0.4 22 June 2010 General Formatting, confirmation of issues resolved as per Neil’s feedback

Faten Leventeris

V.05 19 July 2010 Inclusion of note for SGB as per approval via Amanda Ellis – Matrix update as per feedback SME Stella

Faten Leventeris

V.06 28 February 2013 Incorporation of procedures necessary to comply with the hardship provisions introduced by the Consumer Credit Legislation Amendment (Enhancements) Act 2012 (Cth)

Project Team

v.06 12 March 2013 Updated to include changes suggested by FOS Megan Prest

V.07 31 May 2013 Updated to reflect Policy changes re Financial Capacity Calculator, Mortgage Insurance and incorporating Mortgage Phoenix policy changes

Di Barratt

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Introduction

The Financial Hardship Policy applies to all situations involving financial hardship. Under the National Credit Code (NCC), the Bank as a credit provider, is obliged to consider any notice given by a Customer who is or will be experiencing difficulties in meeting their obligations under a credit contract and assess their eligibility for financial hardship assistance. This Financial Hardship Policy sets out the procedure that the Bank is to undertake in receiving, assessing and responding to such a notice.

The hardship procedures in this document which relate to Consumer Customers are designed to be used, and must be used in all cases, where a notice is given to the Bank by a Consumer Customer under section 72 of the NCC. (Details enclosed in Appendix A – Legislation)

Although the NCC does not cover Small Business the same consideration is given when requesting assistance.

This Policy applies only to the Bank's Westpac, St George, Bank SA and Bank of Melbourne brands. The RAMs and St George Auto Finance Financial Hardship policies are held separately and are under review.

1. The Assist Group

1.1 What is the Assist Group?

The Assist Group is a Team within Collections that specialise in finding solutions for Consumer and Small Business Customers experiencing financial hardship. The Assist Group’s Solution Specialists assess Customers’ individual situations, and provide personalised assistance, information and solutions to help Customers manage their financial obligations with the Bank during their time of financial difficulty.

The Assist Group takes direct (public 1800) and referred Inbound calls. The Assist Group welcomes calls from both pre-delinquent and delinquent Consumer and Small Business Customers experiencing financial hardship. Note: All of Collections are able to offer assistance to customers in financial difficulty; those in Hardship or longer term financial difficulty are referred to Assist Group.

1.2 Who does the Assist Group help?

The Assist Group can offer financial assistance to Consumer and Small Business Customers holding credit products with Westpac , St George, (excluding St George Auto Finance) Bank SA and Bank of Melbourne who are experiencing financial hardship. Financial Hardship occurs when a Customer is willing but unable to meet their existing financial obligations for a period of time. Examples of situations which might cause financial hardship include, but are not limited to:

• Unemployment • Reduced income • Injury or illness (including carer responsibilities) or death of a family member • Separation and divorce • Natural disaster • Over commitment or indebtedness

Solutions are provided on a case by case basis dependant on; • Customer circumstance • Payment serviceability • Recoverable position

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The focus is on sustainable solutions which meet the individual customer need. All Customers requesting assistance and all offers of repayment will be considered and referred to a higher Credit Authority Limit (CAL) holder if applicable. (Details of CALs enclosed in Appendix B) The Assist Group will refer customers to Financial Counsellors when specialised Financial advice is required. In cases where customers are proactively seeking Financial Counsellor services, and have advised the Bank, Collections activity will be held for 21 days to allow the customer reasonable time to have an appointment with a Financial Counsellor. Should more than 21 days be required the onus is on the customer to keep the Bank informed to continue the hold on Collections activity.

2. Types of Financial Hardship Assistance Offered by the Assist Group

2.1 Account Restructure

The Assist Group administers and manages suitable account restructures for eligible Customers. An account restructure enables the Customer the opportunity to reduce or defer their current debt obligations with the Bank in the short term so that they can manage through a period of financial hardship. An account restructure involves a variation to the Customer's credit contract.

An account restructure can take the form of:

• An extension of the loan term (within product loan term boundaries), which results in a reduced repayment amount

• A short term fixed/reduced repayment for an amount below the contractual repayment amount or below the minimum monthly payment, which may be accompanied by an interest rate reduction

• A short term moratorium or a deferral of repayments which may be accompanied by an interest rate reduction

• An interest rate reduction or shading

• A debt consolidation

• A re-age or capitalisation of arrears;

• A debt settlement

• Any other account restructure that the Bank considers appropriate within the limits of this Financial Hardship Policy.

Note: In the instance of Disaster stand alone package offers apply as advised by the Bank’s Australian Financial Services (AFS) division. All changes to a Customer's credit contract arising out of an account restructure are documented in a Letter of Variation or a Letter of Notification sent to the Customer. (To be applied on a case by case basis, examples of Mortgage Solutions enclosed in Appendix C, Credit Cards Appendix D, Personal Loans Appendix E, Transaction accounts Appendix F and WEF Appendix G)

2.2 Escalation to Long Term or Permanent Collection Procedures

Under extreme cases of hardship, such as those that arise as a result of severe or terminal illness, disablement, long term unemployment, long term loss of contract or supplier etc, it is doubtful the Customer will be able to move out of a position of financial hardship and therefore meet the ongoing obligations of their debt with the Bank. Customers experiencing incurable or permanent financial hardship may be candidates for long term or permanent collection procedures, for example but not limited to:

• Long term/permanent payment arrangements

• Partial write-off with long term payment arrangements

• Debt consolidation with long term payment arrangements

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3. Processing a Request for Hardship Assistance

3.1 Receiving a Hardship Notice

Whenever a Customer informs the Bank that they consider themselves unable to meet their obligations under their credit contract (Hardship Notice), they will be referred to the Assist Group. The Assist Group will record receipt of the Customer's Hardship Notice, which is deemed to have been given on the day that the Hardship Notice is first received by any Bank employee, either orally or in writing.

The Assist Group will determine why the Customer is unable to meet his or her obligations under the credit contract, and what type of change he or she is seeking to make to the credit contract as a result.

3.2 Responding to a Hardship Notice

3.2.1 No further information required

Where no further information is required from the Customer in order to assess the Customer's Hardship Notice, the Assist Group will give the Customer a notice stating whether or not the Bank and the Customer have agreed to change the credit contract within 21 days of the date on which the Bank received the Hardship Notice.

3.2.2 Request for further information

Where further information is required of the Customer in order to assess the Hardship Notice, the Assist Group will provide the Customer with a notice, either orally or in writing, which requires the Customer to provide the information specified in the notice. This notice will be provided to the Customer within 21 days of the date on which the Bank received the Hardship Notice.

The information requested of the Customer in such a notice must be relevant to deciding:

- whether the Customer is or will be unable to meet their obligations under the credit contract; or

- how to change the contract if the Customer is or will be unable to meet their obligations under the credit contract.

The Customer is required to comply with such a request. If the Customer does not provide any of the information in accordance with the notice, the Assist Group will give the Customer a notice stating whether or not the Bank and the Customer have agreed to change the credit contract within 28 days of giving the Customer the notice requiring the further information.

Where the Customer provides any or all of the information requested in the notice, the Assist Group will give the Customer a notice stating whether or not the Bank and the Customer have agreed to change the credit contract within 21 days of having received the first of that information.

3.2.3 Notices

Notification of decision

Once the Assist Group has assessed the Hardship Notice, the Bank will give a written notice to the Customer stating either:

(a) that the Bank and the Customer have agreed to change the credit contract; or

(b) that the Bank and the Customer have not agreed to change the credit contract, and also stating:

• the reasons why they have not agreed;

• the name and contact details of the external dispute resolution scheme of which the Bank is a member (the Financial Ombudsman Service FOS); and

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• the Customer's rights under the FOS scheme.

Notice of change

Additionally, where the Bank and the Customer have agreed to change the Customer's credit contract, a written notice setting out the particulars of the change/s to the terms of the contract will be provided to the Customer, and any guarantor, within 30 days of the date of the agreement. This requirement may be met in respect of the Customer by including the particulars of the change with the letter advising that the Bank and the Customer have agreed to change the credit contract (referred to above).

If there is a guarantee related to the credit contract, the guarantor's consent will be sought to extending the guarantee to secure the Customer's liabilities under the credit contract as changed. This requirement, as well as the requirement to provide the guarantor with details of the changes to the terms of the credit contract (discussed above) may be met by sending the relevant Letter of Variation to the guarantor.

Multiple borrowers

Where there are multiple borrowers under the credit contract, the agreement of all borrowers should be obtained before any change can be made to the credit contract. That agreement may be obtained orally (provided a recording is made and kept), or in writing by sending the appropriate Letter of Variation to each borrower and each borrower signing and returning the Letter of Variation to the Bank.

4. Eligibility and Assessment for Financial Hardship

4.1 Assistance Eligibility 4.1.1 General Eligibility Criteria The following eligibility criteria is to be considered before a financial hardship solution can be offered or before an existing hardship assistance solution can be extended, but every case should be considered for assistance:

• The Customer has adhered to any previous restructure arrangement that was granted under this, unless broken as a result of the customer requesting a variation during the period of assistance

• The Customer demonstrates a future commitment and ability to pay but is unable to make up arrears

or make payments in the short term. This may be due to temporary financial hardship as a result of a temporary reduction or loss of income, or of expenses relating to illness, accident or death, or separation or divorce.

• The Customer has the capacity to meet the ongoing commitments of the restructured loan, or the

Customer can provide details of a recoverable position that will enable them to meet their loan commitments after any assistance period granted has expired and they return to the normal obligations of their loan contract

• If the Customer has had more than two (2) restructures over the life of the facility further approvals

are required and the Financial Capacity Calculator (FCC) is to be utilised to confirm surplus funds. Financial Counsellors may use their Statement of Financial Position in lieu of FCC. (Copy of FCC enclosed in Appendix C)

• Second Assistance Request for same reason within 12 month period based on the following criteria:-

- Arrangements have met the conditions of the initial assistance period AND/OR - Arrangements are still within initial assistance period OR - Initial assistance period has recently expired (<28 days from assistance expiry date) AND - The Total Assistance period including the extension does not exceed 6 months

Further approvals can be sought outside of these guidelines. Note 1: In the instance of Disaster separate eligibility criteria applies as advised by AFS Note 2: Accounts subject to Fraud related issues will be referred to the appropriate department.

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4.1.2 Assessment Solution is determined based on conversation regarding:

• Customer circumstance • Payment serviceability • Recoverable position

All Customers are assessed on a case by case basis. Further approvals can be sought outside of these guidelines.

(To be applied on a case by case basis, examples of Mortgage Solutions enclosed in Appendix D, Credit Cards Appendix E, Personal Loans Appendix F, Transaction accounts Appendix G and WEF Appendix H)

4.1.3 Customers requiring Administrator/Executor approvals The following Customers can be assessed for Assistance; however approval may be required from a further authority such as an Administrator or Executor.

:

• Customer is deceased (excepting where there are multiple borrowers and at least 1 borrower is not deceased)

• The Customer is bankrupt

• The Customer is subject to a Part IX or Part X debt agreement

• The Business Customer is under Administration, Liquidation or Receivership

(E.g. Customer has a mortgage however is subject to a Part IX or X agreement or bankruptcy relating to unsecured debts)

5. Secured Loan exceptions

5.1 Mortgage Insured Loans The Bank’s mortgage insurers have provided a Delegated Hardship Authority (DHA) which enables the Assist Group to act under its documented Financial Hardship Policy arrangements and apply relevant Approvals (CALs) for all mortgage insured loans. This enables the Assist Group to exercise the DHA, that is, approve hardship applications made by borrowers without seeking the mortgage insurer’s prior consent where the hardship application would ordinarily be approved under this Financial Hardship Policy. Where assistance has been provided on a mortgage insured loan the details will be reported to the relevant mortgage insurer by the AFS Secured Risk team each month for those applications approved in the previous month, in the format agreed with the mortgage insurers. This Financial Hardship Policy must be provided to the mortgage insurers upon request, or where changes to this document are enacted. Any material changes proposed to this Financial Hardship Policy should be referred to the mortgage insurers prior to implementation. Note – the Assist Group management team have the final authority for approval or decline of variations to loans covered by the Bank’s mortgage insurers.

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5.2 Breaking a Fixed Term Interest Period A fixed term interest period can be broken where there is the ability to extend the loan term and capitalise the break costs into the loan. Where there is no capacity to extend the loan term, breakage costs may still be capitalised over the remaining loan term. Under any circumstance that the break costs are capitalised into the loan, the Customer must have the long term capacity to service the new repayments inclusive of the capitalised costs. Prior to breaking a fixed term interest period the Assist operator will speak with the Customer about the implications of this

approach and discuss any alternatives. 5.3 Building Insurance If a Customer is in financial hardship and holds a mortgage account without building insurance, loan assistance can be offered, but the Customer is required to obtain satisfactory building insurance after the assistance period has expired and they have returned to the new/amended regular repayments

5.4 Maximum Lending to Value Ratio (LVR) Where third time assistance is sought and Manager’s approval required an up to date valuation may be required. The valuation can be performed as:

• a drive by valuation, • an electronic valuation.

Should the updated valuation value the security at a lesser value than the original valuation, the updated valuation must take precedence. A copy of any updated valuation is to be kept on file. The Bank will speak to the customer about the implications of a given solution before processing.

5.5 Guaranteed Loans Where a guaranteed loan is to be restructured, the relevant Letter of Variation must be provided to the Guarantor, informing the Guarantor of the changes to the terms of the loan. For Equipment Finance loans, a signed copy of the Letter of Variation must be returned by the Guarantor showing acceptance of the changes to the loan.

6. Enforcement Action

If, either before or after the Bank gives a Customer a default notice under section 88 of the NCC, the Customer gives the Bank a Hardship Notice, the Bank must not take enforcement action against the Customer unless:

- the Bank has given the Customer a notice in response to the Hardship Notice stating that the Bank and the Customer have not agreed to change the credit contract; and

- a period of 14 days has passed from the date that the Bank gave such notice.

The Bank may, however, begin enforcement action if the Customer has given another Hardship Notice to the Bank in the preceding 4 months and the Bank reasonably believes that there is no material difference in the basis on which the current and the earlier Hardship Notices were given.

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7. Appendix A - Legislation

7.1 NCC Requirements

The hardship provisions under the NCC apply to each of the following categories of credit contract:

- those entered into prior to 1 July 2010 and regulated by the Uniform Consumer Credit Code, where the maximum amount of credit that could be provided was less than or equal to 110% of the amount of the average loan size for the purchase of new dwellings in NSW;

- those entered into between 1 July 2010 and 28 February 2013 and regulated by the NCC, where the maximum amount of credit that is or may be provided under the credit contract is less than or equal to $500,000; and

- all credit contracts entered into on or after 1 March 2013 and regulated by the NCC.

This policy sets out the requirements that apply on and after 1 March 2013. The Bank follows these requirements in respect of all hardship notices received from Customers under the NCC, regardless of the date on which the credit contract was entered into.

Section 72 of the NCC outlines the legal obligations of the Bank towards Customers experiencing hardship and/or requiring financial assistance to overcome financial difficulties. Section 73 outlines the requirements regarding the notice to Customers of any changes made to a loan under section 72. This legislation applies to all Consumer regulated loans including credit cards, personal loans, and mortgages for personal purposes and residential investment property loans.

`

Section 72: Changes on grounds of hardship

(1) Hardship notice. If a debtor considers that he or she is or will be unable to meet his or her obligations under a credit contract, the debtor may give the credit provider notice (a hardship notice), orally or in writing, of the debtor’s inability to meet the obligations.

Note: If the debtor gives the credit provider a hardship notice, there may be requirements (beyond those in section 88) that the credit provider must comply with before beginning enforcement proceedings—see section 89A.

(2) Further information. Within 21 days after the day of receiving the debtor’s hardship notice, the credit provider may give the debtor notice, orally or in writing, requiring the debtor to give the credit provider specified information within 21 days of the date of the notice stated in the notice. The information specified must be relevant to deciding:

(a) whether the debtor is or will be unable to meet the debtor’s obligations under the contract; or

(b) how to change the contract if the debtor is or will be unable to meet those obligations.

(3) The debtor must comply with the requirement.

Note: The credit provider need not agree to change the credit contract, especially if the credit provider:

(a) does not believe there is a reasonable cause (such as illness or unemployment) for the debtor’s inability to meet his or her obligations; or

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(b) reasonably believes the debtor would not be able to meet his or her obligations under the contract even if it were changed.

(4) Notice of decision on changing credit contract. The credit provider must, before the end of the period identified under subsection (5), give the debtor a notice:

(a) that is in the form (if any) prescribed by the regulations and records the fact that the credit provider and the debtor have agreed to change the credit contract; or

(b) that is in the form (if any) prescribed by the regulations and states:

• the credit provider and the debtor have not agreed to change the credit contract; and • the reasons why they have not agreed; and • the name and contact details of the approved external dispute resolution scheme of

which the credit provider is a member; and • the debtor’s rights under that scheme.

Civil penalty: 2,000 penalty units.

(5) The credit provider must give the notice before the end of the period identified using the table.

Period for giving notice

If: The period is:

1 The credit provider does not require information under subsection (2)

21 days after the day of receiving the hardship notice

2 The credit provider requires information under subsection (2) but does not receive any information in compliance with the requirement

28 days after the stated date of the notice under subsection (2)

3 The credit provider requires information under subsection (2) and receives information in compliance with the requirement

21 days after the day of receiving the information

(6) Regulations may prescribe shorter periods for credit contracts. The regulations may provide for

subsections (2), (3), (4) and (5) to have effect in relation to credit contracts prescribed by the regulations as if a particular reference in subsection (2) or (5) to a number of days were a reference to a lesser number of days prescribed by the regulations.

Section 73: Notice of change

(1) A credit provider that enters into an agreement with the debtor to change the credit contract as a result of a hardship notice by the debtor must, not later than 30 days after the date of the agreement, give to the debtor, and any guarantor under a guarantee related to the contract, a written notice setting out –

(a) Particulars of the change in the terms of the contract; and

(b) Any information required by the regulations.

(2) The credit provider may, under subsection (1), give a person particulars only of a matter as changed instead of particulars of the changes, but only if the credit provider –

(a) Makes it clear to the person that the matter has changed; or

(b) Issues to the person a new set of terms and conditions relating to the credit contract.

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7.2 The Code of Banking Practice

Section 25 of the Code of Banking Practice outlines the Bank’s obligations to assist Customers experiencing financial difficulties. The Code of Banking Practice applies to both consumer regulated loans and credit cards as well as certain business and investment loans.

Section 25.2: Provision of credit

25.1 Before we offer or give you a credit facility (or increase an existing credit facility), we will exercise the care and skill of a diligent and prudent banker in selecting and applying our credit assessment methods and in forming our opinion about your ability to repay it.

25.2 With your agreement, we will try to help you overcome your financial difficulties with any credit

facility you have with us. We could, for example, work with you to develop a repayment plan. If, at the time, the hardship variation provisions of the National Credit Code could apply to your circumstances, we will inform you about them.

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8. Appendix B - Credit Authority Limits (CALs)

Schedule A

Collections - General Consumer Authorities CAL Grid: Credit approval limits

Approval Authority Level 1

Head of

Collections

Level 2

Senior

Manager

Level 3

Business

Unit

Manager

Level 4

Team

Leader

Level 5

Specialist

Team

Member

Level 6

Team

Member

Level 7

Team

Member

Level 8

New

Team

Member

TAE

(Total Assessed

Customer Exposure

Combined value of

all customer

products)

$7.5m $5m $3m $2.5m $1.5m $500k $500k $500k

Incremental Lending

Secured* $500k $400k $200k $100k $50k $20k $10k $2k

Incremental Lending

Unsecured $50k $25k $10k $5k – $2k $2k $1k

TOD (temp

overdrafts) $100k $20k $10k $5k – $2k $2k $1k

Term extension

Mortgage

Personal loans

40 yrs 40 yrs 40 yrs 40 yrs 40 yrs 40 yrs 40 yrs 40 yrs

12yrs 12yrs 12yrs 12yrs 12yrs 12yrs _ _

Life Tenancy Yes Yes – – – – – –

Debt consolidation $25k

Limited only

by TAE

$20k

Limited

only by

TAE

$15k

Limited

only by

TAE

$10k – – – –

Debt settlement

(Unsecured)

(cents per dollar)

0.00¢ 0.00¢ 0.10¢ 0.30¢ 0.50¢ 0.50¢ 0.80¢ Nil

Interest Shading –

Mortgage**

Unsecured

100%

(12mth)

100%

(12mth)

100%

(12mth)

100%

(6mth) Nil Nil Nil Nil

100% 100% 100% 100%

(12mth)

100%

(6mth)

100%

(6mth) Nil Nil

Write off direct $25k $100k $50k $20k $5k $5k $2k –

Fee / Interest

reversal $50k $40k $30k $20k $5k $5k $1k $100

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Payment

arrangement-

Mortgage

Unsecured

Unlimited Unlimited 24mths. 12mths 6mths 6mths 6mths 3mths

Unlimited Unlimited 24mths 12mths 6mths 6mths 6mths 21days

Capitalisation of

arrears (re-age) $150k

Limited only

by TAE

$100k

Limited

only by

TAE

$50k

Limited

only by

TAE

$40k

Limited

only by

TAE

$25k $25k $25k $25k

Schedule B

Collections - Mortgage Recoveries CAL Grid: Credit approval limits

Approval authority Level 1

Head of

Collections

Level 2

Senior

Manager

Level 3

Business

Unit

Manager

Level 4

Team

Leader

Level 5

Specialist

Team

Member

Level 6

Team

Member

Level 7

Team

Member

Level 8

Probation

Provisions (new,

increased, decreased,

write-off from

provision)

$2m $1m $500k $250k $50k – – –

Write off Direct $1m $250k $100k – – – – –

Securities

• Enforcement

• Release

$5m $3m $2m $1m $500k $250k – –

All credit related legal

/ civil actions $1m $500k $250k $200k $50k – – –

**Debt sales (below

reserve based on

NPV)

$20m $10m – – – – – –

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Schedule C

Collections - Unsecured Recoveries CAL Grid: Credit approval limits

Approval

authority

Level 1

Head of

Collections

Level 2

Senior

Manager

Level 3

Business

Unit

Manager

Level 4

Team

Leader

Level 5

Specialist

Team

Member

Level 6

Team

Member

Level 7

Team

Member

Level 8

Probation

Write off direct

– under policy $200k $150k $100k $75k $20k – – –

Repurchase $200k $150k $100k $75k $20k – – –

Schedule D Secured NPL CAL

Approval authority Level 1

Head of

Collections

Level 2

Senior

Manager

Level 3

Business

Unit

Manager

Level 4

Team

Leader

Level 5

Specialist

Team

Member

Level 6

Team

Member

Level 7

Team

Member

Level 8

Probation

*Account Management (TAE)

$1m $500k $250k $250k $100k $100k $50k $20k

*Incremental Lending

$100k $50k $20k $10k $5k $5k $2k $1k

Write Off from Provision

$500k $500k $250k $250k - $100k - -

**New Provisions/Write Off Direct

$1m $200k $100k $50k - $20k $20k -

Increased-Provisions/Write Off Direct

$250k $100k $50k $20k - $10k - -

Securities:-Enforcement, Release

$1m $500k $250k $250k - $10k $50k -

All credit related Legal/Civil Actions

$100k $50k $20k $10k - $2k $5k -

***Debt Sales (below reserve based on NPV)

$20m $10m - - - - - -

* Except where over ridden by Policy/Automated Collection Strategies ** Level 7 WOD authority only relates to Debt Agreements and Debt Settlements *** Authority does not apply to Head of Collections

9. Appendix C – Financial Capacity Calculator (FCC)

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MONTHLY NET INCOME

Monthly Net Salary or Wage:

(exclusive of overtime, bonuses, incentives

and commissions)

Employment mode: Employment mode:

Overtime:

(Where not a condition of employment, only

include if 6 mth history of regular payments)

Condition of employment?: Condition of employment?:

Industry Payments:

(e.g. s ite allowance, tool allowance, housing

allowance, location allowance etc.)

Commissions:

(Net monthly amount)

Incentives:


Bonuses:


Self Employed Income:

(net monthly business or profit drawing)

Directors Fees:

(PAYG only)

Salary Sacrifice Super Contributions:

(contributions above Super Guarantee

component)

Private Pension or Annuity:

(Monthly instalment)

Rental Income After Tax:

(Average net monthly income after mgt fees,

strata fees, rates levies, land tax etc)

Investment Income:

(Monthly income from deposits and bonds)

Dividends:

(Last full financial year dividend amount

averaged over 12 months)

Social Security:

(Unemp benefits, Aged Pension, Austudy,

Family Benfit Tax, Parenting payment etc.)

Child Maintenance / Alimony:

TOTAL MONTHLY NET INCOME $0 $0

EXTERNAL LOAN COMMITMENTS

External Credit and Store Cards:

(Sum of all limits, or balances where

balances higher than limits)

Or f ixed repayment amount:

Charge Cards:

(Sum of all limits, or balances where

balances higher than limits)


Hire Purchase, Leases, Interest Free

Promotions:

(Contractual monthly repayment amount)

External Personal Loan:

(Contractual monthly repayment amount - if in

joint names, customer's share of payment)

External Mortgage or Investment Loan:

(Contractual monthly repayment amount - if in

joint names, customer's share of payment)

Loan value:

External Overdrafts:

(Sum of fees and interest per month payable

on fully drawn limit)


TOTAL EXTERNAL LOAN COMMITMENTS $0 $0

OTHER FIXED EXPENSES

Higher Education Loan Plan (HELP):

(Only include where customer does not have

this already deducted from their salary)

Include:Estimated Amount:

$0

Estimated Amount:

$0

Rent or Board:

(Monthly rent or board amount - if customer

shares rent, customers share of rent only)

Private School or University Fees:

(Total annual fees averaged over 12 months)

Childcare Costs:

(Net of Childcare Rebate)

Child Maintenance / Alimony

Payments:

(Monthly obligation)

Foxtel / Pay TV:

(Monthly obligation)

Mobile Phone Expense:

(Average monthly bill amount)

Broadband connection:

(Average monthly bill amount)

Other known expenses:

(e.g. medical expenses, legal fees, tax

liabilities, insurance premiums etc.)

TOTAL OTHER FIXED EXPENSES $0 $0

ASSIST - FINANCIAL CAPACITY CALCULATOR

Current Position Long Term Position

Can customer use these

funds for clearance of

arrears?

Can customer sell shares

and use funds for clearance

of arrears?

Assess using minimum amount receiv ed per month

ov er last 6 mths, or if customer is receiv ing or

If customer expects a new job, enter the expected

monthly income f or this new job assuming it is within

Only include if customer is expected to retain these

assets throughout period of hardship.


ov er last 6 mths


ov er last 6 mths, or if customer expects lesser


ov er last 6 mths


ov er last 6 mths, or if customer expects lesser

Assess using minimum amount receiv ed per

month ov er last 6 mths

If bonus to be paid in

hardship period could this be

used in clearance of

arrears?

An assessment of Prof it Loss Statement, Balance Sheet and Notice of Assessment should be undertaken to

determine position of business and ensure salary and prof it drawings are sustainable. Documents will also highlight

Should stop contributions to

free funds for repayment of

debt obligations.

If customer elects to stop these contributions, then include contribution amount as part of the

salary/w age or self -employed income box

Customer must be able to ev idence ongoing nature of this source of income.

If af ter tax income is not av ailable, assess at 75% of pre-tax income net of f ees, lev ies, land tax etc.

Only include if div idend amount to be paid during

period of hardship.

Only include if customer is expected to retain these

assets throughout period of hardship.

Exclude pay ments that the customer would no longer

be eligible f or based on the customre's expected long

If customer on external assistance or in

arrears, enter monthly repay ment amount



Can customer trade dow n or

dispose of asset to relieve

debt?

If customer on external assistance or in arrears, enter

monthly repay ment amount required of the customer.

If customer on external assistance or in arrears, enter

monthly repay ment amount required of the customer.



Depending on customer's

f inancial position, may need

to consider w ithdraw ing

child from school

If contract can be cancelled

w ithout excessive penalties,

customer is expected to

cancel and use funds

tow ards debt obligations




cancel and use funds

tow ards debt obligations

unless dependent on phone




cancel unless required for

income generation or study

Only include if expected to

fall due during period of

hardship

Save and Print ResetLoad Data Exit

If rebate will not be paid during hardship period,

assess as gross monthly amount to be paid.

Print FINANCIAL CAPACITY ASSESSMENT

WBC.107.005.0331

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Page 17 of 26

10. Appendix D - Mortgage Solutions Table The following table outlines the levels of assistance that can be applied to Mortgages, to be applied on a case by case basis Level Circumstance Policy 1 Customer able

to maintain payments but cannot clear arrears.

• Arrears are frozen at commencement of assistance period. • After the customer makes 3 consecutive scheduled repayments, the account may be re-aged. • No interest moratoriums permissible.

Customers > 90 days and/or have had a default notice issued at time of assistance:

- If no current default notice, the standard process will be to issue a Default Notice followed by a Postponement Notice at the commencement of the arrangement.

- Where the Customer upholds and completes the agreed arrangement, the current default notice will be void, however, where the Customer breaks the agreed arrangement, the current default notice expiry date will continue if applicable.

- First instance of broken arrangement and customer reverts to standard Collections treatments and hardship flag removed.

- >90 days mortgages managed by Secured Recoveries team

2 Customer able to maintain a level of repayment, but less than the minimum amount required.

• Arrears frozen at commencement of assistance period. • No interest moratoriums permissible. • Assist to determine if term extension will support proposed reduced repayment amount. If so, after

three consecutive demonstrated repayments at the lower amount, the account is re-aged and term extended. If not, the account is referred for Level 3 activity.

• Customers > 90 days and/or have had a default notice issued at time of assistance:




WBC.107.005.0332

Page 18 of 26


3 Customer able to maintain a level of repayment, but less than the minimum amount required, and a term extension (Level 2) is not suitable.

• Arrears frozen at commencement of assistance period. • No interest moratoriums permissible. • Customer to enter a monitoring style arrangement where a minimum of 25% of the minimum

repayment amount may be accepted for a maximum of six months. The term of the arrangement may be extended for a maximum of a further six months but a minimum of 50% repayments will be required during this secondary period.

• Account re-aged at the completion of the maintained assistance period, at which time the loan repayments will also be amended to the minimum to repay the loan in its ‘recovered’ position over the remaining term (including after a term extension has been factored in).

• Customer to be contacted in every case where an arrangement is not adhered to (except where assistance is deemed to have failed) or otherwise at a minimum of 4 weeks prior to the hardship expiry date. Assistance will be deemed to have failed if a customer fails to adhere to the agreed assistance arrangement twice. In all cases where assistance fails a decline letter will be issued and the account will be referred to the mortgage recoveries team for the issuance or actioning of a default notice.

- Interest Only Loans For interest only loans Level 3 policy to apply as above, with the following additional actions to be taken:

o Facility ‘limit’ to be amended to the post assistance loan balance at the end of the assistance period

o Redraw option on the facility to be switched off, with a Note added to the file advising that the Redraw option can only be turned back on when the loan balance has been reduced down to the pre-assistance level (with ‘limit’ also reduced accordingly)

• Customers > 90 days and/or have had a default notice issued at time of assistance:





WBC.107.005.0333

Page 19 of 26

4 Where a Customer cannot maintain any level on repayments, in exceptional circumstances management approval can be sought.

• Interest moratoriums are permissible.

Note: Interest moratoriums will only be deemed ‘non commercial’ arrangements and included in regulatory reporting as G9 – Prudential Restructures where the interest foregone exceeds $5001

• CAL based decisions supported by an enhanced quality control framework.

• Interest Only Loans

- If approved under Level 4 authority, interest only will require the following additional actions to be taken:

o Facility ‘limit’ to be amended to the post assistance loan balance at the end of the assistance period

o Redraw option on the facility to be switched off, with a Note added to the file advising that the Redraw option can only be turned back on when the loan balance has been reduced down to the pre-assistance level (with ‘limit’ also reduced accordingly)

Disaster Where a customer is impacted by natural disaster

• Offered only to customers affected by natural disaster if < 90 days in arrears at time of assistance sought. Policy defined as:

- Deferral of repayment (no interest moratorium) for up to 3 months. - Freezing of arrears position (no upfront re-aging). - Upfront agreement to tenor extension and/or increased repayments post assistance period. - Re-age after the 3 months assistance period

• Customers with arrears > 90 days at the time assistance is sought will be considered for relief under standard non-disaster Assist policy.

• Post assistance period customers may be considered for Level 3/4 assistance subject to standard criteria.

1 Limit has been set at $500 on the basis of this amount being an equivalent value of fees generally waived in the origination and collections process under

standard commercial arrangements.

WBC.107.005.0334

Page 20 of 26

11. Appendix E - Credit Card Account Assistance Matrix Solutions are provided on a case by case basis dependant on; • Customer circumstance • How Much can the customer pay

• Recoverable position Level Current

Negative Long Term Type of Restructure Other considerations

Fixed payment

Moratorium Reduced Interest

Fee/Interest Reversal

Re-age Debt Settlement

1 Can’t pay Can’t pay NO NO NO NO NO YES Consider debt waiver/debt settlement – refer to TL/Manager

2 Can’t pay Can pay something

N/A NO YES NO YES YES Perm FX and/or a moratorium, possible debt settlement – discuss with TL/Manager

3 Can’t pay Can pay N/A YES YES NO YES NO Consider a FX for someone who may be starting new job to ease from cant pay now but can pay in the future

4 Can pay something

Can’t pay NO NO NO NO NO YES Debt settlement or Debt waiver could be an option – discuss with TL/Manager eg customer leaving employment due to illness

5 Can pay something

Can pay something

YES NO YES YES YES YES Consider perm FX, reduced interest at 12%-10%-5% don’t always select 0%

6 Can pay something

Can pay YES NO YES YES YES NO If there may be a future cost eg a medical expense; consider a reduced payment and interest rate for term required

7 Can pay Can’t pay N/A N/A N/A N/A N/A N/A Debt settlement or Debt waiver could be an option – discuss with TL/Manager eg customer leaving employment due to illness

8 Can pay Can pay something

N/A N/A N/A N/A N/A N/A If customer is contacting the Bank with impending hardship assess current capacity under expected hardship situation.

9 Can pay Can pay N/A N/A N/A N/A N/A N/A If customer requires time to sell assets etc to reduce commitments a short term fixed payment arrangement or period of reduced interest could be considered.

REMEMBER – THIS IS A GUIDE. IF MATRIX SAYS NO BUT YOU BELIEVE A SPECIFIC SOLUTION IS NEEDED FOR YOUR CUSTOMER DISCUSS

WITH YOUR TEAM LEADER OR MANAGER

WBC.107.005.0335

Page 21 of 26

12. Appendix F - Personal Loan Account Assistance Matrix Solutions are provided on a case by case basis dependant on; • Customer circumstance • How Much can the customer pay

• Recoverable position

Level Current Negative

Long Term Type of Restructure Other considerations

Fixed Payment

Deferred Payment

Reduced Interest

Fee / Interest Reversal

Capitalisation of Arrears

Term Extension

Debt Settlement

1 Can’t pay Can’t pay NO NO NO NO NO NO YES Consider debt waiver/debt settlement – refer TL/Manager

2 Can’t pay Can pay something

NO YES YES NO YES YES YES Consider Fee/Interest reversal to reduce debt, and reduced repayment with term extension

3 Can’t pay Can Pay NO YES YES NO YES YES NO Rather than capping consider if Fee/Interest reversal within CAL would be more cost effective

4 Can pay something

Can’t pay YES NO YES NO NO NO YES Consider debt settlement or debt waiver in certain situations eg widowed pensioner

5 Can pay something

Can pay something

YES NO YES YES YES YES YES Consider Fee/Interest reversal to reduce debt, and reduced repayment with term extension

6 Can pay something

Can Pay YES NO YES YES YES YES NO Debt settlement on unsecured could be viable eg 80% now rather than arrangement over 10 years

7 Can Pay Can’t pay N/A N/A N/A N/A N/A N/A N/A If there may be a future cost eg a medical expense; consider a reduced payment and interest rate for term required, debt settlement can also be considered

8 Can Pay Can pay something

N/A N/A N/A N/A N/A N/A N/A If there may be a future cost eg a medical expense; consider a reduced payment and interest rate for term required, debt settlement can also be considered

9 Can Pay Can Pay N/A N/A N/A N/A N/A N/A N/A If customer requires time to sell assets etc to reduce commitments a short term fixed payment arrangement a short term fixed payment arrangement or period of reduced interest could be considered.

REMEMBER – THIS IS A GUIDE. IF MATRIX SAYS NO BUT YOU BELIEVE A SPECIFIC SOLUTION IS NEEDED FOR YOUR CUSTOMER DISCUSS WITH YOUR

TEAM LEADER OR MANAGER

WBC.107.005.0336

Page 22 of 26

13. Appendix G - Transaction Account Restructure Table Solutions are provided on a case by case basis dependant on; • Customer circumstance • How Much can the customer pay

• Recoverable position

Level

Current

Long Term

Type of Restructure

Notes Fixed

Payment Deferred Payment

Reduced Interest

Fee / Interest Reversal

Debt Settlement

1

Can’t Pay

Can’t Pay

YES1

YES1

YES1

NO

YES

1. Only offer a deferred payment (with reduced interest) where loans can be restructured via fixed payments after the deferral period.

2

Can’t Pay

Can Pay

NO

YES

YES

NO

NO

3

Can Pay Something

Can’t Pay

YES

NO

YES

NO

YES

4

Can Pay Something

Can Pay Something

YES

NO

YES

YES

YES

5

Can Pay Something

Can Pay

YES

NO

YES

YES

NO

REMEMBER – THIS IS A GUIDE. IF MATRIX SAYS NO BUT YOU BELIEVE A SPECIFIC SOLUTION IS NEEDED FOR YOUR CUSTOMER DISCUSS WITH

YOUR TEAM LEADER OR MANAGER

WBC.107.005.0337

Page 23 of 26

14. Appendix H - Equipment Finance Account Restructure Table Equipment Finance Loans are required to have a FCC completed to determine position when relevant documentation not available such as

Profit and Loss Statement, Trading Statement and Projected Income. Solutions are provided on a case by case

Capacity Scenario

Type of Restructure

Notes

Reduced Payment

Deferred Payment

Reduced Interest

Fee / Interest

Reversal

Capitalisation of Arrears

Term Extension

Debt Settlement

1

(Current: Negative

Long Term: Insufficient)

NO

YES1

NO

NO

YES 5

YES1

YES6

1. Only offer a deferred payment (with reduced interest) where loans can be restructured via term extension to allow Customer sufficient capacity to meet long term loan commitments (see Term Extension under Glossary for maximum term extension periods). For Secured loans if cannot reduce repayments to within Customers long term capacity, Customer may need assistance to sell security or Bank may have to take possession.

2. Ensure any capitalisation or fixed or deferred payment does not result in increased repayment amounts which are outside the Customer’s long term capacity. May need to adjust the loan term where possible to avoid over committing Customer.

3. For Secured loans Customer may need assistance to sell security or Bank may have to take possession. If Customer requires assistance to sell, offer a fixed payment arrangement (with reduced interest) for up to 3 months to assist Customer to manage debt while arranging sale of security.

4. Offer a loan term extension where the new repayments are within the Customer’s current and long term capacity. If the repayments are outside the Customer’s current capacity, but within their long term capacity, also offer a fixed payment arrangement (with reduced interest) over the expected hardship period. For Secured loans if term cannot be restructured, or is outside of Customer’s long term capacity, Customer may need assistance to sell security or Bank may have to take possession.

5. Arrears should only be re-capitalised once Customer has gained employment or moved past period of hardship and has demonstrated ability to meet ongoing debt obligations for a minimum of 3 months.

6. Debt Settlement must only be offered post sale of the security.

2

(Current: Negative

Long Term: Sufficient)

NO

YES 2

NO

NO

YES 2, 5

YES

NO

3

(Current: Insufficient

Long Term: Negative)

YES 3

NO

NO

NO

NO

NO

YES6

4


Long Term: Insufficient)

YES 3, 4

NO

NO

YES

YES 5

YES 3, 4

YES6

5


Long Term: Sufficient)

YES 2

NO

NO

YES

YES 2, 5

YES

NO

WBC.107.005.0338

Page 24 of 26

15. Appendix I - Glossary AFS Australian Financial Services Can Pay Customer can make normal repayments but possibly cannot make up arrears Can Pay Something Customer can pay something however not full amount of repayments Can’t Pay Customer cannot pay anything

Debt Settlement

A debt settlement allows the Customer and the Bank to negotiate a compromise on the Customer’s outstanding debt with the Bank (e.g. an agreement may be reached with the Customer to pay 50c in the dollar on all outstanding balances). Settlement of the Customer’s debt(s) is in the form of a lump sum payment that is paid within 14 days from when the settlement agreement is made with the Bank. Where a debt settlement agreement is made between the Customer and the Bank, a letter confirming the details of the settlement is issued to the Customer. The Customer is requested to make payment within 14 days from the settlement arrangement date. Where payment is not received within 14 days, a follow up call is made to request payment, if not paid the account should re- enter normal collections activities for the full outstanding balance. When the debt settlement payment is received, the account is written off, the un-repaid balance is abandoned, and the account is closed.

Drive by Kerbside Valuation

A drive by kerbside valuation is obtained from a valuer listed on the Bank’s Valuation Panel. A valuation of this kind usually provides a value range for the property. The mid-point of this value range should be relied upon as the value for the security when calculating Loan to Value Ratio.

Financial Capacity Calculator (FCC) A tool used to determine the customer’s capacity to pay based on income and expenditure. Normally used for third time assistance and for Business requests such as Equipment Finance when relevant documentation not available eg Profit and Loss Statement, Trading Statement, Projected income Fixed or Reduced Repayments

A fixed payment or a reduced payment is a set amount the Bank negotiates with the Customer to pay each month across the period the payment arrangement is granted. For a credit card account, the fixed payment amount is usually set below the minimum payment amount. The interest rates applicable to the outstanding balance (i.e. cash rates, purchase rates and balance transfer rates) is negotiated and adjusted with a fixed payment, to ensure the Customer’s outstanding balance does not continue to grow over the period of the fixed payment arrangement. For an amortising loan (e.g. a mortgage or personal loan) the reduced payment amount will be set below the contractual repayment amount. If the reduced payment amount is less than the interest component of the contractual repayment amount, the interest component of the contractual repayment amount may be capitalised into the loan, or shaded over the period of the reduced payment arrangement. After the reduced repayment period has expired, independent of interest rate movements, it is probable the contractual repayment amount will increase due to the loan balance not being reduced sufficiently over the arrangement period to repay the loan within the loan term. It is important that this higher contractual repayment amount is not outside the Customer’s ongoing capacity. A Customer is normally offered a reduced repayment arrangement where they either have sufficient long term capacity for the increased ongoing repayment amount, or where a loan term extension can

WBC.107.005.0339

Page 25 of 26

be offered to bring the ongoing repayment amount to within the Customer’s capacity. Letter of Variation

A Letter of Variation (LOV) is a formal letter to all parties of the account (primary account holder(s) and any guarantor(s)) outlining the changes to their account and loan contract that are to result from a restructure. The primary account holder(s) and any guarantor(s) are requested to return a signed acceptance of these changes before the account restructure can be implemented. A follow up call is made to the customer if the LOV has not been returned prior to the end of the assistance period. Note that it is acceptable to send a Letter of Notification in place of a Letter of Variation if the account changes resulting from a restructure are verbally accepted by the Customer. Where there are multiple borrowers, the changes must be verbally accepted by all borrowers. If there is a guarantor, the guarantor's written acceptance is required.

Letter of Notification

A Letter of Notification (LON) is a formal letter to the Customer outlining the changes to their account resulting from a verbally accepted offer of restructure. The letter is for the Customer’s records only, and does not need to be signed or returned to the Bank.

Moratoriums or Deferred Repayments

A Moratorium or deferred repayments means the Customer is not required to make any repayment for an arranged period. For a credit card account, the interest rates applicable to the outstanding balance (i.e. cash rates, purchase rates and balance transfer rates) should be reduced or set to 0%, to ensure the Customer’s outstanding balance does not continue to grow over the period.

For an amortising loan (e.g. a mortgage or personal loan) the interest component of the contractual repayment amount may be capitalised into the loan or shaded over the deferred payment period. After the expiry of the deferred payment period, the contractual repayment amount will increase due to the loan balance not being reduced over the period to allow the loan to be repaid within the loan term. It is important that this higher contractual repayment amount is not outside the Customer’s ongoing capacity. A Customer should only be offered a deferred payment period where they either have sufficient long term capacity for the increased ongoing repayment amount, or where a loan term extension can be offered to bring the ongoing repayment amount to within the Customer’s capacity.

Re-age or Capitalisation of Arrears

For a credit card account, a re-age sets the delinquency status back to current, and the amount overdue back to zero. The current balance and limit remains unchanged. For an amortising loan (e.g. a mortgage or personal loan) arrears can be capitalised into the loan, hence removing the amount overdue and resetting the delinquency status back to current. The limit will be increased against the contractual limit with a recapitalisation, and repayments will be recalculated on the new limit over the remaining term, hence resulting in increased contractual repayment amounts. It is important that this higher contractual repayment amount is not outside the Customer’s ongoing capacity. A Customer should only be offered capitalisation of arrears where they either have sufficient long term capacity for the increased ongoing repayment amount, or where a loan term extension can be offered to bring the ongoing repayment amount to within the Customer’s capacity. A re-age or capitalisation of arrears will be applied to an account once the Customer has maintained their obligations under any assisted hardship period. Reduced Interest

Interest is normally reduced for a negotiated period of time. Reduced interest can be used as an exclusive financial assistance solution, or can be used to administer other account restructures such as reduced or deferred payments. Under long term or permanent collection procedures the interest rate may be reduced for the life of the account, subject to the relevant Credit Authorities. Small Business

WBC.107.005.0340

Page 26 of 26

Small Business relates to Business Direct and Local Business Banking segments under the Bank’s Manager Numbers 0 – 99. The Bank uses the Basel II definition of small business, which defines a small business as a business with borrowings up to $1 million. Note that the Code of Banking Practice defines small business as “a business having less than 100 full time people if it is or includes manufacture of goods, or in any other case less than 20 full time people”. Should a small business satisfying the Code of Banking Practice definition not fall under Manager Numbers 0 – 99, then this Financial Hardship Policy would still apply to that business.

Term Extension

For an amortising loan (e.g. a mortgage, business, equipment finance or personal loan) the term can be extended within the following limits. Maximum term extension:

Mortgage: Up to maximum loan term (see below) Personal Loan: Up to maximum loan term (see below) Business Loan: Up to maximum loan term (see below) Equipment Finance: If remaining term is less than 18 months, term can be extended to a maximum of 6

months for Team Leader and above CAL holders, and a maximum of 3 months for team member CAL holders. If the remaining term is 18 months or more, no term extension is to be granted – arrears are to be amortised over the existing term.

Maximum loan term:

Mortgage: 30 years from date of restructure, and not beyond 40 years from origination date. Personal Loan: 12 years Business Loan: - 25 years where fully secured by residential security;

- 15 years where fully secured by non-specialised commercial real estate or non- specialised rural land; - 10 years where reliant on Business Assets or specialised security

.

WBC.107.005.0341